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  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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CONSTANCE MCNEIL, SB# 184526
E-Mail: meneil@|bbslaw.com

SUSAN FRENCH, SB# 129421 ELECTRONICALLY
E-Mail: french @Ibbslaw.com FILED

LEWIS BRISBOIS BISGAARD & SMITH LiP Superior Court of California,

One Sansome Street, Suite 1400 County of San Francisco

San Francisco, California 94104

Telephone: (415) 362-2580 G oARR 20.2009

Facsimile: (415) 434-0882 BY: ANNIE PASCUAL.

Deputy Clerk

Attorneys for Defendant
PLANT INSULATION COMPANY

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA, ASBESTOS

Plaintiffs, CASE NO. 274230

JOINDER OF DEFENDANT PLANT
INSULATION COMPANY TO THE
WILLIAM POWELL COMPANY’S
MOTION FOR PROTECTIVE ORDER RE:

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Defendants. ) PLAINTIFF’S DEPOSITION
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ASBESTOS DEFENDANTS (B&P),

Date: May 11, 2009

Time: 10:30 a.m.

Dept.: 610

Judge: Comm, Bruce E, Chan

Action Filed: June 6, 2007
Trial Date: None Set

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that Defendant PLANT INSULATION COMPANY (“PLANT”)
hereby joins in the Notice of Motion and Motion For Protective Order Re: Plaintiff's Deposition,
filed by its co-defendant THE WILLIAM POWELL COMPANY (“WPC”). WPC’s Motion is to
be heard on May 11, 2009, at 10:30 a.m. in Dept. 610 of the above-referenced Court and seeks at a
minimum an additional twenty (20) hours so as to obtain the rest of Plaintiff's testimony and
ascertain the extent to which Plaintiff has facts to support his claimed exposures and each
Defendants’ role, if any, therein.

4838-2834-6115.1 -l-

JOINDER OF DEF. PLANT INSULATION CO. TO THE WILLIAM POWELL CO.’S MOTION FOR
PROTECTIVE ORDER RE: PLF’S DEPO.Dn WwW B

For purposes of this joinder, Defendant PLANT hereby adopts and incorporates by
reference, WPC’s moving papers as if their own, including the Notice of Motion, Motion and
Memorandum of Points and Authorities and exhibits and declarations filed by WPC in support of
their Motion; any Joinder, together with all pleadings and documents filed this matter by other co-
defendants herein. PLANT is prepared to proceed with the motion and hearing as scheduled even
if WPC or any other joining party withdrew the motion or is no longer a party.

As more fully detailed in the Memorandum of Points and Authorities filed by WPC,
PLANT was also faced with additional instances of Plaintiff's use of a product and an additional
refinery site when PLANT began its questioning. Plaintiffs lengthy pauses and detailed responses
made it impossible to cover both product uses and the activities of PLANT employees during
Mr. Castagna’s work history. As such, to be able to properly defend itself and to evaluate the
case, PLANT asserts its need for additional time to depose Plaintiff.

Plaintiffs will not be prejudiced by this Joinder because they have already been provided
reasonable and legally sufficient notice of the motion and the scheduled hearing date.

Dated: April 20, 2009 LEWIS BRISBOIS BISGAARD & SMITH Lip

By /s/ Susan French
Susan French
Attorneys for Defendant
PLANT INSULATION COMPANY

4838-2834-6115.1 -2-

JOINDER OF DEF. PLANT INSULATION CO. TO THE WILLIAM POWELL CO.’S MOTION FOR
PROTECTIVE ORDER RE: PLF’S DEPO.Dn WwW B

Louis Castagna v. Asbestos Defendants, et al.
San Francisco County Superior Court Case No, 274230

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION

STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO

lam employed in the County of San Francisco, State of California. | am over the age of 18
and not a party to the within action. My business address is One Sansome Street, Suite 1400, San
Francisco, California 94104.

On April 20, 2009, I electronically served (E-Service) via LexisNexis File and Serve
pursuant to General Order No. 158, the following document described as:

JOINDER OF DEFENDANT PLANT INSULATION COMPANY TO THE
WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE:
PLAINTIFF’S DEPOSITION

on all interested parties in this action by placing [X]atrue copy [ ] the original thereof enclosed
in sealed envelopes addressed as follows:

Attorneys for Plaintiff:

Brayton “Purcell LLP
222 Rush Landing Road
P.O. Box 6169

Novato, California 94948
Telephone: (415) 898-1555
Facsimile: (415) 898-1247

The above document was transmitted by Lexis-Nexis E-Service and the transmission was
reported as complete and without error.

[X] | (STATE) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.

Executed on April 20, 2009, at San Francisco, California.

‘si Betty J. Ramirez
Betty J. Ramirez

4838-2834-6115.1 -3-

JOINDER OF DEF. PLANT INSULATION CO. TO THE WILLIAM POWELL CO.’S MOTION FOR
PROTECTIVE ORDER RE: PLF’S DEPO.